Revised Program to Reduce Benzene Emissions from Glycol Dehydrators

Transcription

1 Directive 039 July 10, 2006 Revised Program to Reduce from Glycol Dehydrators The Alberta Energy and Utilities Board and Alberta Environment have approved this directive on July 10, [Original signed by] [Original signed by] M. N. McCrank, Q.C., P.Eng. C. Peter Watson, P.Eng. Chairman Deputy Minister Alberta Energy and Utilities Board Alberta Environment This directive sets out new requirements for the reduction of benzene emissions from glycol dehydrators and replaces the joint Alberta Energy and Utilities Board (EUB) and Alberta Environment (AENV) Informational Letter (IL) : Revised Program to Reduce from Glycol Dehydrators. These requirements will also be incorporated into EUB Directive 060: Upstream Petroleum Industry Flaring, Incineration, and Venting, (formerly Guide 60: Upstream Petroleum Industry Flaring Guide). With the issuance of this directive, the EUB and AENV have established mandatory requirements to ensure continued reductions of benzene emissions to reduce potential impact on the public. Licensees must comply with the following new requirements effective January 1, 2007: 1) When evaluating dehydration requirements in order to achieve the lowest possible benzene emission levels, licensees must use the Decision Tree Process in Appendix A of the Canadian Association of Petroleum Producers (CAPP) document Best Management Practices for Control of from Glycol Dehydrators, June 2006 ( Control BMP) and retain appropriate analysis documentation for review by regulatory agencies. Licensees must follow the public consultation process outlined in the Control BMP. 2) Licensees must ensure that all their dehydrators meet the following benzene emission limits. Date Dehydrator Installed or Existing Dehydrator Relocated Prior to January 1, 1999 Greater than 750 m to permanent resident or public facility Less than 750 m to permanent resident or public facility January 1, 1999, to January 1, 2007 After January 1, 2007 Emission Limits 5 tonnes/yr 3 tonnes/yr 3 tonnes/yr 1 tonne/yr EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 1

2 Specific Emission Limits i) If more than one dehydrator is located at a facility or lease site, the cumulative benzene emissions for all dehydrators must not exceed the limit of the oldest dehydrator on site. Modifications may be required to existing unit(s) to meet the site limit. ii) Any new or relocated dehydrators added to an existing site with dehydrator(s) must operate at a maximum benzene emission limit of 1 tonne/yr or less. The cumulative benzene emissions must not exceed the limit of the oldest dehydrator on site. iii) For dehydrators that are only in operation for a portion of the year, the daily emission rate must not exceed the above annual benzene emission limits divided by 365. (For example, for a dehydrator with an annual benzene emission limit of 3 tonnes that only operates for six months of the year, the maximum annual emission limit would be 1.5 tonnes or a maximum daily emission rate of 8.2 kg/day.) See Section 2.3 of the Control BMP for details on calculating and reporting of emissions from dehydrators that only operate a portion of the year. 3) Licensees must complete a Dehydrator Engineering and Operations Sheet (DEOS) (see Attachment 1) to determine the benzene emissions from each dehydrator. This sheet summarizes optimum operating conditions to minimize benzene emissions and must be posted at the dehydrator for use by the operations staff and inspection by the EUB. The DEOS must be revised annually (each calendar year), upon relocation, or upon a change in status (resume operation, shut-in, bypassed) of the dehydrator. 4) Licensees must complete and submit an annual Dehydrator Inventory List (see typical inventory list in Attachment 2), listing all the licensees dehydrators, as set out in the June 2006 CAPP Control BMP by July 1 each year. Copies of the annual Dehydrator Inventory List form are available from CAPP at This information must be submitted to the EUB through the Multi-Stakeholder Technical Advisory Team ( TAT) (by mail to Attention: Manager of Alberta Operations, CAPP, Suite 2100, Avenue S.W., Calgary, Alberta T2P 3N9; or by to benzene.tat@capp.ca). The latest version of the Control BMP is available from CAPP at This document describes procedures for selecting appropriate dehydration, calculating emissions, maintaining records, and reporting reductions of benzene emissions from glycol dehydrators. Questions regarding the document and the processes it outlines may be directed to CAPP at (403) or by e- mail at benzene.tat@capp.ca. Compliance and Enforcement These requirements will be subject to compliance review by the EUB. Regulatory requirements are those rules that industry has an obligation to meet and against which the EUB may take enforcement action in cases of noncompliance. For the purpose of Directive 039, noncompliance events are listed in Attachment 3. See the EUB Web site at and Directive 019: EUB Compliance Assurance Enforcement for details regarding EUB compliance and enforcement. AENV may also review for compliance, and failure to comply may result in the issuance of Environmental Protection Orders (EPO), as outlined in the Alberta Environmental Protection and Enhancement Act. 2 EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006)

3 Background Contact is classified as a toxic substance under the Canadian Environmental Protection Act and as a Group 1 carcinogen by the International Agency for Research on Cancer. As a nonthreshold carcinogen, there is considered to be some health risk at any level of exposure. As a result, benzene emissions must be managed to achieve the lowest levels practicable to minimize human exposure. A Workplace Health and Safety Sheet (Attachment 4) was prepared by the TAT to promote awareness of benzene hazards and methods to minimize exposure for operations staff. As described in IL , the oil and gas industry has had a Reduction Program in place since The program is managed by the TAT, which includes representatives from Health Canada, CAPP, Environment Canada, EUB, AENV, B.C. Environment, and Saskatchewan Environment. A recent status report shows that only 26 per cent of new dehydrator installations have used the Decision Tree Process outlined in the November 2000 CAPP BMP for Control of to optimize dehydrator performance to reduce benzene emissions to as low a level as possible. While the TAT is encouraged by the benzene emission reductions achieved from glycol dehydrators, it has determined that new requirements are needed to maintain current reductions achieved, strive for continuous improvement in controlling emissions, select appropriate dehydration, improve reporting of emissions, and operate dehydrators more efficiently. The new requirements in this directive should result in dehydrators being operated at optimum conditions to ensure that emissions and potential health effects from benzene are minimized. Any comments or questions with respect to this directive should be directed to the EUB s Environment Group at (403) or by at eub.enviroservices@gov.ab.ca or to the AENV Environmental Policy Branch at (780) or by at randy.dobko@gov.ab.ca. EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 3

4 Attachment 1 Dehydrator (Dehy) Engineering and Operations Sheet (DEOS) Version Date: June 2006 (This sheet must be revised annually, or upon dehydrator relocation or change in status, and posted at the dehy.) Technical Contact: Print Name/Phone #/ Revision Date (dd-mm-yyyy): Facility or Site Name: Licensee Name: Operator Name: Gov t Licence No: Location, DLS: _ W _( or NTS: ) Installation Type: Well Compressor Battery Plant Cavern Other DEHY Type: TEG DEG EG Date Dehy installed/relocated? (dd-mm-yyyy): Current Dehy Status: Producing Shut-In Bypassed Other: Date Dehy Status Changed? (dd-mm-yyyy): Typical number of operating days per year: Number of dehys on site: Distance to Closest Resident (if < 750 metres): Normal Gas Flow Rate to Dehy: (e 3 m 3 /d): Content in Gas to Dehy (mole %): (If zero, Dehy operations sheet must still be posted) Feed gas benzene determination method: Analysis Date of analysis (dd-mm-yyyy): Other (describe): Glycol Pump Make/Model# Normal Pump Speed: RPM or SPM Plunger diameter/stroke length: inches, or mm Normal Glycol Circulation: USgpm Normal Absorber Temp: C Normal Absorber Press: kpag Emission Calculation Method: GRI GLYCalc TM Version #: HYSYS TM ProSim TM Total Capture Rich/Lean Glycol Other Describe: Emission Controls: No Yes Describe (condenser, tank, incinerator, flare, other): Dehy decision tree analysis (DTA) completed?: No Yes (mandatory for all new or relocated dehys) When operating, average benzene emissions (in tonnes/yr)* Before Controls: After Controls: *Note: In accordance with EUB Directive 039, this dehydrator must be operated below tonnes/yr benzene emissions. If multiple dehys exist on this site, the aggregate benzene emissions must be less than tonnes/yr, which is the maximum per year allowed for the oldest dehy on site. Wet Gas to dehy contains 61 lbs w ater per mmscf or kgs w ater per e3m3 Typical Dehydrator Operations 7,580 kpag, 40 C, 100 ppm benzene, 98.6% TEG Dry Gas Water Content (lbs/mmscf) Emission Limit (tonnes per Year) Circulation Rate USgpm Graph Prepared by : 3.5 mmscfd (100 e3m3/d) 7.0 mmscfd (200 e3m3/d) 7.0 mmscfd (200 e3m3/d) 4 EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006)

5 Page 1 of 2 Attachment 2 Canadian Oil and Gas Industry - Annual Dehydrator Inventory List For: 2006 (yyyy) Company Net Gas Production: 10 3 m 3 /day Instructions: This form must be completed and submitted annually by July 1st for the previous year of operations. Upon completion, submit this form to the Technical Advisory Team by to benzene.tat@capp.ca Attention: Manager of Alberta Operations, CAPP DEOS Completed Multiple Dehys on Site? Company Data Revision Date: July 1, 2007 Date Submitted to CAPP: July 1, 2007 Licensee Operating Company Name Field Name BC Centizone Unique Identifier Complete LSD W4 LSD Sect Twn Rge Mer Installation Type Glycol Type Dehydrator Use (Installation Type) Operating Status Production Status Normal gas flowrate to dehy Concentration (Gas to Dehy) Number of Operating Days per year Rate While Operating Annual for dehydrator Prior After to Control Control Yes Yes / No Compressor TEG Operating 10 3 m 3 /day days kilograms/day tonnes Mole % for each dehy No / Specify: Battery DEG Shut-in or shut-in - Shut In Wellsite EG De-commissioned or by-passed, or Number of Operating Days x - Separator Ops Gas Plant Other By-passed operating as separator Rate - Sold Storage Cavern Operating as a separator or other Field Name BC Centizone Complete LSD LSD Sect Twn Rge Mer Other Other Example Data: Yes Yes ABC Resources Inc. Sample Location Field W Compressor TEG Operating % Yes Yes ABC Resources Inc. Sample Location Field W Compressor TEG Operating % *Note: Copies of the Annual Dehydrator Inventory List Forms are available from CAPP at EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 5-6

6 Page 2 of 2 Annual Dehydrator Inventory List (continued) Above Dehy Limit? Cumulative Annual For all dehydrators on site Above Site Limit? Calculation Method Emission Control Method Installed / Modified after Jan. 1, 2001? Installation Details Date of Installation/ Relocation, if known Decision Tree Analysis Completed? (EUB Directive 039) Number of dehys on site For This Dehy Allowed Annual For This Dehy Allowed Daily Oldest Dehy Allowed Annual Oldest Dehy Allowed Daily Yes / No tonnes Yes / No GRI-GLYCalc No Control / Emit to Atmosphere Yes / No yyyy-mm-dd Required for all tonnes/yr kilograms/day tonnes/yr kilograms/day m Yes / No yyyy-mm-dd HYSYS Aboveground/ Underground Tank New/ Show dehy limit Show dehy limit Flag red if Prosim Flare / Incinerator Relocated Show dehydrator Show dehydrator <750 m Total Capture Process Optimization Dehydrators limit only limit only Add up the emissions from all previous rows per site. Leave single dehys blank. Distance to Closest Residence Were residents contacted? of oldest dehy on of oldest dehy on site if more than site if more than Rich/Lean Glycol Commercial Condenser one dehy one dehy Other (describe) Other (describe) a c Date Site Record Changed Comments Additional Comments No GRI-GLYCalc No Control Yes 2/1/2001 Yes ,120 No 10/12/2005 New unit No 2.50 No GRI-GLYCalc No Control No 2/1/1998 Yes ,120 No 10/12/2005 Old unit *Note: Copies of the Annual Dehydrator Inventory List Forms are available from CAPP at EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 5-6

7 Attachment 3 Noncompliance Enforcement Ratings Enforcement Rating High Low Low Low Noncompliance Event Dehydrator or site benzene emissions over the limits Failure to complete Decision Tree analysis Dehydrator Engineering and Operations Sheet (DEOS) not done, incomplete/inaccurate, and/or not posted Failure to submit annual Dehydrator Inventory List to TAT If all noncompliance items are not addressed, escalating consequences will be applied in accordance with Directive 019: EUB Compliance Assurance Enforcement (Directive 019). Operators should also be aware that if they are identified as persistently noncompliant, enforcement will be applied as outlined in Directive 019. The EUB encourages companies to voluntarily self-disclose any noncompliances as described in Section 6 of Directive 019. EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 7

8 Attachment 4 Workplace Health and Safety What is benzene?, a colourless, flammable liquid with a sweet odour, is classified as a toxic substance under the Canadian Environmental Protection Act. As a non-threshold carcinogen, it is considered to be of some health risk at any level of exposure. It is also classified as a Group 1 carcinogen by the International Agency for Research on Cancer (IARC). It is to be managed by reducing human exposure to the extent possible and practicable. Where is benzene found in the workplace? Crude oil and natural gas condensate contain benzene. The concentration varies depending on the geology and location of the well site. and other hydrocarbons may be released from stacks, flares, glycol dehydrators, hydrocarbon storage facilities, and other operations that involve crude oil or condensate. Occupational exposure to benzene in the upstream oil and gas industry occurs mainly through the use of glycol dehydrators as benzene is removed from the gas stream during dehydration. How can workers become exposed to benzene? Workers may become exposed by inhalation or by direct contact with the skin. This may occur when changing filters and pumps and when handling rich glycol at dehydrators. Although readily absorbed after inhalation, benzene is not easily absorbed through skin contact. The absorption of benzene vapour through the skin is unlikely to be significant at concentrations below 25 ppm. What are the health risks of benzene exposure? Short-Term Acute Exposure Acute exposures (greater than 3200 µg/m 3 or 1000 ppb over an 8-hour period) are unlikely during routine operations and worker activities. Limited studies suggest that acute exposure to benzene may depress the central nervous system. Common symptoms at 50 to 150 ppm are drowsiness, dizziness, headache, nausea, vomiting, sleepiness, fatigue, nose and throat irritation, slurred speech, loss of balance, and disorientation. Exposure above ppm for 5 to 10 minutes can cause death. Long-Term Chronic Exposure Chronic exposure may result in a range of health effects, depending on the dose and frequency of exposure. Health effects of prolonged exposure relate mainly to the skin and blood. Prolonged and repeated contact with benzene can cause redness, drying, and cracking of the skin. Prolonged exposure above workplace limits may suppress the production of red blood cells, white blood cells, and clotting cells by damaging bone marrow. may also increase the incidence of a specific type of leukemia (acute myelogenous leukemia) and other forms of leukemia and lymphomas. Exposure to benzene along with other substances may enhance health effects. Exposure to benzene and ethanol can increase the effects on the blood system. Exposure to toluene and benzene can reduce the body s ability to remove benzene, as toluene slows the rate of clearance of benzene by competing for metabolic pathways. How can you avoid exposure to benzene? Engineering Controls Optimize glycol circulation. Implement alternatives for hydrate control and dehydration, such as using a flash tank separator, a line heater, or solid desiccant or molecular sieve plants. Ensure that equipment and barriers for preventing exposure are working and maintained according to specifications. 8 EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006)

9 Administrative controls Verify that safe work practices are formalized, reviewed, and updated. Ensure that employees are properly trained in safe work practices. Monitor air to ensure that the benzene concentration does not exceed the occupational exposure limit. Personal protective equipment Use close-fitting goggles or a National Institute for Occupational Safety and Health (NIOSH)- approved supplied-air respirator (SAR) with a full face mask that includes an end-of-use indicator. Wear, wash, and maintain chemical-resistant clothing (gloves, coveralls, boots) appropriate for conditions of use. EUB Directive 039: Revised Program to Reduce from Glycol Dehydrators (July 10, 2006) 9